Mealey's (February 25, 2022, 4:00 PM EST) -- PHILADELPHIA — An estate administratrix’s wrongful death action alleging violations of the Federal Nursing Home Reform Act (FNHRA), “including for failing to maintain adequate care plans,” suffices to infer that a nursing home’s conduct involved “reckless or callous indifference” to nursing home residents’ rights, a Pennsylvania federal judge held Feb. 16, denying the nursing home’s motion to strike allegations related to punitive damages and motion to dismiss “under a failure to train theory” but granting the motion to dismiss FNHRA claims under the inadequate staffing theory....